Section 1 Conflict Mineral Disclosure
Item 1.01Conflict Mineral Disclosure and Report
This
Conflict Mineral Disclosure for the year ended December 31, 2020, is presented to comply with Rule 13p-1 (the Rule) under the Securities Exchange Act of 1934 (the Exchange Act). The Rule was adopted by
the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act). These reporting
obligations are imposed on SEC registrants whose manufactured products contain conflict minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined in Section 1502(e)(4) of the Dodd-Frank Act
as (A) colum-bite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their
derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an ad-joining country (Covered
Countries).
It is the policy of Universal Stainless & Alloy Products, Inc. (USAP) to utilize minerals in the products it manufactures that
are conflict-free. Section 13(p)(1)(D) of the Exchange Act defines conflict-free as products that do not contain conflict minerals that directly or indirectly benefit armed groups in the Covered Countries. USAP does not use
tantalum, tin or gold in its products. The only relevant conflict mineral USAP may utilize in its products is tungsten. The tungsten used by USAP in the products it manufactures is exclusively supplied by recycled or scrap sources (i.e.,
conflict-free). USAP represents that it has obtained certification that each supplier, scrap or otherwise, supplies only conflict-free tungsten.
Reasonable Country of Origin Inquiry
Based on a
good faith Reasonable Country of Origin Inquiry, USAP reasonably believes that any tungsten used in its products did not originate from Covered Countries; or alternatively, came from a recycled or scrap source. This determination is
equally applicable to the activities of each USAP subsidiary.
A Reasonable Country of Origin Inquiry can differ among issuers based on the issuers
size, products, relationships with suppliers, or other factors. The steps necessary to constitute a Reasonable Country of Origin Inquiry depend on the available infrastructure at a given time, must be reasonably designed to determine whether the
conflict minerals did originate in Covered Countries, or did they come from recycled or scrap sources, and it must be performed in good faith. In order to satisfy its Reasonable Country of Origin Inquiry, USAP sent out an inquiry to each tungsten
supplier and received written confirmation directly from each that the tungsten provided to USAP did not originate in the Covered Countries; or alternatively, came from a recycled or scrap source. Most, if not all, of these suppliers have a long
standing relationship with USAP and USAP has no reason to believe that these representations are not reliable or true.
Based on the foregoing Reasonable
Country of Origin Inquiry, USAP is not required to exercise due diligence on its conflict minerals source or chain of custody or file a Conflict Mineral Report (CMR) with respect to such conflict minerals. USAPs only
obligation is to briefly describe both the Reasonable Country of Origin Inquiry it undertook and the corresponding results as set forth hereinabove.